OVERVIEW

The House plan to tax imports and exempt exports (the
"border adjustment tax" or
"B.A.T.")1 is part of a tax reform package
that is expected to raise more than $1 trillion to offset lower
income tax rates and improve U.S. competitiveness against global
rivals. It is designed to encourage U.S. companies to move
manufacturing operations back to the U.S. or use U.S.-based, rather
than foreign-based, manufac­turers.

Sixteen major U.S. companies, including Boeing Co., General
Electric Co., and Caterpillar Inc., recently urged Congress to
adopt the B.A.T. with an eye toward establishing more competitive
pricing for U.S. manufactured goods.2

However, the B.A.T. also raises concerns for certain
manufacturers – retooling to a U.S. supply line is costly and
can take many years to setup. Of course, the se­verity of the
retooling problem may be looked at as a driving reason for adopting
a policy of encouraging manufacturing in the U.S. Ultimately, the
B.A.T. will not be a winning proposition for all American
businesses, as it benefits corporations that are net exporters to
other countries, rather than companies who import goods to sell to
the U.S. market.

On the international stage, the potential losers and others have
already raised a loud outcry against adoption of the B.A.T. The
proposal likely will be challenged in the World Trade Organization
("W.T.O.") by member nations that will be harmed by the
tax.

Set forth below is a description of those industries that are
expected to be helped and harmed by this proposal and an
examination of the potential impact on U.S. currency. Also, set
forth below are likely arguments that will support a challenge in
the W.T.O. and a discussion of the impact on the American consumer
– who may be the biggest loser if the plan is adopted. Note
that most of the arguments addressed to consumers are championed by
retailers that source inventory abroad.

EFFECT ON THE VALUE OF THE U.S. DOLLAR

There is some divergence as to whether the B.A.T. will result in
an increase in the value of the U.S. dollar. Since the border tax
will materially alter the terms of trade between the U.S. and the
rest of the world, the border tax could be expected to lead to a
sharp increase in the value of the dollar.3

Per economic theory, there will be a reduction in U.S. demand
for imported prod­ucts, and as such, U.S. consumers will
transfer fewer U.S. dollars to foreign sellers, thereby reducing
the global supply and raising the value of the dollar.
Consequently, it would be more expensive for foreign buyers to
purchase U.S. goods and cheaper for U.S. importers to purchase
goods from overseas. Yet, other analysts believe that the sale of
goods will have very little effect on the dollar, as the U.S. has
already transitioned from an economy principally based on goods to
one based on knowl­edge and technology.4

The dollar could rally 25% – to levels not seen since the
1980's – according to economists, including Harvard
University's Martin Feldstein, who was chairman of the Council
of Economic Advisors under President Ronald Reagan.5
U.S. holders of foreign assets would see the value of those foreign
assets drop. This also sug­gests that the dollar denominated
purchase price of foreign produced products will drop. Because many
foreigners borrow in U.S. dollars, some commentators have
speculated that a global debt crisis may follow for those that do
not hedge foreign currency exposure in their home
country.6

Martin Feldstein, however, believes that the critics of the
border tax have not taken into account that the rise in value of
the U.S. dollar will serve to offset any possible price adjustments
that may result from the tax. Feldstein illustrates this by looking
at the impact on an imported product that now costs $100. The
purchase price of this imported product will rise to $125 so that
the net effect of the 20% border tax will be a price of $100.
Feldstein computes this as follows: the new $125 import price is
reduced by a 20% tax on that amount (or $25) so the net price
equals the present $100. Feldstein then asserts that "a 25%
rise in the dollar would reduce the import cost to $80 – that
is, $100 divided by 1.25. The border tax would then raise the
domestic selling price to the original $100, so the importer could
pay 20% of that and have $80 left to cover the cost of the
import."7 Feldstein's technical economic
observations that there will be no negative impact to American
industry and the consumer have not been embraced by other
commentators and have been silenced the critics of the tax.

WINNERS AND LOSERS

Potential winners with regard to the B.A.T. will likely be (i)
companies that are U.S. exporters and (ii) companies with
significant input costs produced in the U.S. As previously
mentioned, the C.E.O.'s of 16 major U.S. companies recently
signed a letter to Congress endorsing the B.A.T. (the
"Letter"). The signatories represent:

Boeing

Caterpillar

Celanese Corp.

Celgene Corp.

CoorsTek

Dow Chemical Co.

General Electric

Eli Lilly and Co.

McIlhenny Company

Merck & Co Inc.

Raytheon Co.

S&P Global Inc.

Oracle Corp.

United Technologies Corp.

Pfizer Inc.

Varian Medical Systems Inc.

While these businesses have clearly determined that they fit
into one or both of the foregoing categories, the following
discussion outlines the industries and sectors that are thought to
be helped or harmed by the B.A.T.

Aircraft Manufacturers

Companies that produce American-made aircraft for commercial or
private use are expected to benefit from the B.A.T. An example is
Boeing, which argues that its primary competitor, Airbus, similarly
benefits from V.A.T. refunds for non-E.U. sales while Boeing
aircraft are subject to V.A.T. in the E.U. However, if Boeing or
other aircraft manufacturers import parts or subassemblies as part
of their supply chains, they will be adversely effected by the
border tax. This may affect the makeup of supply chains for U.S.
manufacturers.8 However, the elimination of tax on
exports of aircraft should far outweigh the cost of the B.A.T. on
subassemblies.

American Consumers

A common theme echoed by many industries is that the B.A.T. will
result in higher prices for the American consumer.9

The Americans for Affordable Products Coalition
("A.A.P.C."), a group of 150 busi­nesses and trade
coalitions, was formed to protest the B.A.T.10 The
A.A.P.C. esti­mates that the tax will raise the cost of
everyday products like food, gas and med­icine by up to 20% and
threaten millions of jobs. It also indicated that this could have a
harmful effect on middle-income American families and result in
potentially evaporating 27% of their savings with the increased
cost caused by the tax. Some notable members of A.A.P.C. are
retailers like Target Corp. and Macy's, Inc., and
im­port-focused trade associations like the National
Association of Beverage Importers and the National Grocers
Association.11

Americans for Prosperity ("A.F.P.") is a conservative
political advocacy group in the U.S., which is funded by the
businessmen and philanthropist brothers David H. Koch and Charles
Koch. A.F.P. opposes the concept of funding lower corporate rates
by increasing consumer prices. It criticized the border adjustment
plan as a tax on consumers.12

Automotive Industry

No matter where assembled, automobiles sold in the U.S. contain
a large number of components produced abroad. One consulting firm
recently prepared a report projecting the anticipated price
increase that would result from the B.A.T. Ford Motor Co. would
raise prices by an average of $282 per vehicle while GM would raise
prices a $995 price hike. For other manufacturers, the projected
increases are $1,312 for American Honda, $1,672 for Fiat Chrysler
Automobiles, $2,298 for Nis­san North America, and $2,651 for
Toyota. Mazda Motors imports its full lineup and its projected
increase is $5,156 per vehicle. The American International
Automobile Dealers Association argues that impact of the B.A.T.
will be to lower new car sales.13

Clothing and Apparel Industry

The U.S. clothing and apparel market comprises about 28% percent
of the global total. Americans buy nearly 20 billion garments a
year – close to 70 pieces of cloth­ing per person.
Roughly 2% of that is made in the U.S.14 Thus, B.A.T. is
likely to adversely affect this industry severely.

Companies with Locally Sourced I.P.

For politicians concerned about U.S. base erosion from royalty
payments for the use of intangible property ("I.P.")
owned outside the U.S., the B.A.T. may incentivize corporations to
forego transfers of I.P. to foreign affiliates based in low-tax
jurisdic­tions. Additionally, if the corporate tax rate falls
to 20% or 15%, there may be little incentive left for U.S.
corporations to move I.P. offshore.

Energy Sector: Oil Drillers and Refiners

The energy sector in America comprises both drillers and
refiners. Domestic drillers stand to benefit from the B.A.T. and
support the proposal. However, there is a split among
refiners.15

The U.S. is the largest producer of shale oil in the world, and
while the U.S. produc­es about 8.6 million barrels of crude oil
per day, it imports about 8 million barrels of crude oil on the
same basis. Under the B.A.T., the cost of imports would no longer
be deductible. Most imports come from Canada, but others come from
Mexico, Colombia, Venezuela, and Saudi Arabia. Saudi crude oil is
shipped to the Saudi Aramco owned plant in Texas.16
Refiners on the east or west coasts, such as Tesoro Corp. and
PBF Energy, rely heavily on this imported crude and are opposed to
the tax. Refiners with a better mix of domestic crude and the
ability to export fuel prod­ucts are more neutral to the
idea.17

There is concern that gas prices may increase by up to 20% for
consumers due to the increased tax on imported crude oil. Goldman
Sachs Group Inc. projects that U.S. oil prices could surge to $65 a
barrel from a recent $54, reflecting a sharp tightening in the
supply-demand balance in the U.S. market.18 Internal
reports of the American Petroleum Institute have concluded that the
proposal will raise gasoline prices by $0.20 per gallon or more in
the short term.

This is somewhat less than a recent tax increase per gallon on
gasoline sold in the State of New Jersey. Anecdotally, the price
increase did not result in less conges­tion within the
state.

Supporters of the proposal have argued that the B.A.T. will
strengthen the U.S dol­lar, which will offset any short-term
surge in gas prices. The American Fuel and Petrochemical
Manufacturers ("A.F.P.M.") have also concluded that gas
prices will surge. A.F.P.M. tends to represent refiners and
cautions that the B.A.T. could have considerable impact on
refiners, consumers, and the economy."19

Food and Agriculture Sector

California farmers supply much of the produce that is on the
shelves of American supermarkets,20 and most domestic
producers – particularly U.S. corn exporters – stand to
benefit from the tax. Nonetheless, foreign growers supply a
substantial portion, too, especially in the winter months.

Over the last decade, there has been a growing U.S. trade
deficit in fresh and pro­cessed fruits and vegetables. Although
U.S. fruit and vegetable exports totaled $6.3 billion in 2015, U.S.
imports of fruits and vegetables were $17.6 billion, resulting in a
gap between imports and exports of $11.4 billion (excludes nuts and
processed nut products). This trade deficit has generally widened
over time as growth in imports has outpaced export growth. As a
result, the U.S. has gone from being a net ex­porter of fresh
and processed fruits and vegetables in the early 1970's to
being a net importer of fruits and vegetables today.21
This of course may change if consumers shy away from imported
products from jams to fruits.

Mexico sold $10.4 billion of fruits and vegetables to the U.S,
in 2015 making it the biggest supplier of produce from abroad.
Products include tomatoes, avocados, peppers, grapes, cucumbers,
melons, berries, and onions. Canada is the second biggest supplier
with sales of $2.9 billion in 2015. Bananas are from tropical
re­gions. Most of the bananas you buy are grown within 20
degrees on either side of the equator.22

Machinery Manufacturers

The American company Caterpillar is one of 16 signatories to the
Letter supporting the B.A.T. It is expected that Caterpillar and
its American competitor, John Deere, as net exporters, would stand
to benefit from the B.A.T. In comparison, foreign com­petitors
such as Komatsu and Mahindra will likely be damaged by the B.A.T.
when they import machinery to the U.S. The comparison of U.S.
manufacturers and their foreign competitors in this category
illustrates a potential weakness of the B.A.T., as the B.A.T. may
be construed as a subsidy that provides a financial benefit to U.S.
residents. For example, while Caterpillar and John Deere can deduct
the cost of goods sold in computing taxable income under the
B.A.T., Komatsu and Mahindra are subject to a gross sales tax.

Military Contractors

Since the U.S. is the world's leading arms
exporter,23 companies manufacturing military arms and
equipment are enthusiastic proponents of the B.A.T. Note that
because U.S. law prevents U.S. military technology from being
produced outside the U.S., most of the inputs are sourced in U.S.
Raytheon and United Technologies are signatories to the letter
endorsing the B.A.T.

Retail Industry

The retail industry is the nation's largest private-sector
employer, providing and supporting more than 42 million American
jobs, and many existing retailers are un­dergoing significant
changes brought about by the rise of online competition. With the
implementation of the B.A.T., major retailers such as Walmart and
Target will be hit with increased costs, as most merchandise they
sell is sourced abroad – from apparel to electronics. In
fact, 95% of shoes and clothing sold in the U.S. is made
elsewhere.24

There is a view that the value of the U.S. dollar will increase
as a result of the B.A.T. and that increase will soften price
increases. However, officers of major brand cloth­ing have
argued it is disingenuous to state that currency changes would
even-out the impact of the B.A.T. The comment is reflective of the
current almost universal view of U.S. retailers.25

These companies face a choice of absorbing some or all the cost
of the tax or pass­ing some or all of the cost to their
customers. Neither result is favorable for retailers, and several
major retail C.E.O.'s recently met with President Donald Trump
and House Ways and Means Committee Chairman Kevin Brady (R-T.X.) at
the White House to express concerns that the tax would hurt their
industry.26 Walmart's an­nounced position is
that the added cost is likely to be passed on to the consumers in
the form of higher prices when shopping at a brick-and-mortar store
or on the internet.

Although retail is generally presumed to be on the losing side
of the B.A.T., there are some retailers that could benefit from the
tax. Stores that operate primarily in the U.S. and sell to
customers who are less price sensitive are within this category.
Examples are Neiman Marcus and Saks Fifth Avenue.

Pharmaceutical Industry

While U.S. drug manufacturers and net exporters Eli Lilly,
Merck, Celgene, and Pfizer were signatories the Letter, the
pharmaceutical industry, which imported over $86 billion in
products in 2015, will be largely harmed by the border tax.

This industry is comprised of companies engaged in researching,
developing, man­ufacturing, and distributing drugs for human or
veterinary purposes. The U.S. is the world's largest
pharmaceutical market with $333 billion in sales in 2015 –
about tri­ple the size of the second largest market, China.
Generic drugs are less expensive for the American consumer and are
favored by insurance companies for reasons of cost. India
contributes around 30% of the overall volume of pharma products
consumed in the U.S.

Directly and indirectly, the industry supports over 3.4 million
jobs across the U.S. and added an estimated $790 billion to the
economy in 2014.27 No estimate is given by trade
associations of the number of jobs that will be lost as a result of
the B.A.T. or the reduction in sales that is projected.

Tourism and Higher Education

Tourism is a major industry in America. A stronger U.S. dollar
means that, at the margins, fewer foreign persons may visit the
U.S. as tourists.28 A stronger dollar also means that
Americans planning a vacation may find traveling abroad much less
expensive. Thus, vacations outside the U.S. may increase, which
would also be harmful to the U.S. tourism industry.

International students comprise a growing share of student
population, especially in hard topics such as science and
math.29 For those who are not on U.S. dollar
de­nominated scholarships, a stronger dollar increases the cost
for a foreign students.

WORLD TRADE ORGANIZATION OPPOSITION

The W.T.O. was formed in 1995 and is composed of 164 member
nations as of July 29, 2016. The W.T.O. provides a framework for
negotiating trade agreements and a forum for resolving trade
disputes among members.30

Many commentators have suggested that the B.A.T. would violate
W.T.O. rules and precipitate a challenge in the W.T.O. by countries
that export to the U.S. U.S. Con­gressman Kevin Brady is the
Chairman of the House Ways and Means Committee and the principal
advocate for the B.A.T. He is convinced the B.A.T. is compliant
with W.T.O. rules. Others believe that it may violate W.T.O. rules
because of the inability to include the cost of imports as part of
cost of goods sold at the same time that the cost of locally made
products can be included in such costs. This may be a form of
subsidy that may violate the Agreement on Subsidies and
Countervailing Measures.31

The definition of a subsidy is composed of three basic elements:
(i) a financial con­tribution (ii) by a government or any
public body within the territory of a W.T.O. member state (iii)
that confers a benefit.32 All three of these elements
must be satisfied in order for a subsidy to exist. A financial
contribution requires a charge on government funds. The term
includes the relinquishment of government revenue or the failure to
collect revenue (as would be the case with a credit or an exemption
from tax generally due on domestic sales).33

In February, the German ambassador to the U.S. expressed concern
that the B.A.T. may not be consistent with W.T.O. rules, but
declined to say whether Germany might file a complaint with the
W.T.O.34

THE TRUMP ADMINISTRATION'S POSITION

President Trump has not yet reached a final decision on whether
to support or oppose the border tax proposal.35 However,
President Trump has expressed concern about the plan calling it
"too complicated" in an interview with the Wall Street
Journal.36

CONCLUSION

Like many controversial issues, belief in the potential adverse
effects of the B.A.T. seems to depend on a company's status as
a net exporter or net importer of inven­tory. To importers,
adoption of the B.A.T. will harm major sectors of the American
economy in a significant manner. They believe that the effect will
be widespread and will embroil the U.S. in a controversy with its
trading partners that will lead to a trade dispute that for
resolution in the W.T.O. These companies argue that the ultimate
consumers of their product may be the biggest losers through higher
prices. Interestingly, industrial labor unions whose members are
consumers seem to be quiet on the issue of the B.A.T.

Footnotes

1 The tax on imports is actually an indirect tax since
the proposal will deny a deduction for the cost of imported goods,
which will increase the taxable gain when those products are later
resold. By contrast, the proposal will exempt gain from the sale of
exports from tax.

U.S. Customs and Border Protection recently announced that it will block imports of goods that were produced with North Korean labor even though North Korean workers were employed outside of North Korea.

The U.S. Department of the Treasury Office of Foreign Assets Control ("OFAC") issued amended Directives and frequently asked questions ("FAQs") in connection with the Ukraine/Russia-related sanctions program.

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